14th October 2011
RE: Submission on the children’s commercial communications code.
To the Broadcasting Authority of Ireland,
Firstly, can I thank you for affording me the opportunity to make a submission, for consideration, as part of the BAI review of its children’s commercial communications code.
While I welcome the review and support the principle behind the mechanism that is being used to define unhealthy foods, I believe that the definition of unhealthy foods cannot be solely based on this formula.
As it is presently constructed the mechanism for defining foods, categorises foods such as diet cola as being “more healthy” than foods such as cheese.
I therefore believe that a black & white formula on its own is not sufficient to cater for all the dietary needs of children, and that a waiver system must be used in conjunction with the assessment mechanism to exclude foods like cheese.
Cheese is a rich source of calcium, which is an essential nutrient and is of critical importance to meet the dietary needs of children especially those between the age of 9 & 18.
While it is correct to say that children can obtain their calcium requirements from other sources such as low fat yoghurt & milk, it would require the consumption of 650g of low fat yoghurt/day or 1ltr of low fat milk/day to ensure an adequate intake of calcium.
A greater balance of foods, which includes cheese would help to ensure that children’s intake of calcium is adequate to meet their dietary needs.
While I fully accept at this present point in time that obesity is, from a population health perspective, of greater importance there is little point addressing one problem only to create another longer term problem, like osteoporosis.
National surveys clearly highlight the prevalence of inadequate calcium intakes among Irish children and teenagers, with 42% of teenage girls and 23% of teenage boys (13-17 years) reported to have insufficient calcium intakes1. Corresponding figures for children (5-12 years) are 37% and 28%, respectively2. These figures have a direct long term impact on the incidence of osteoporosis.
The report Strategy to Prevent Falls and Fractures in Ireland’s Ageing Population3 was jointly prepared by the Health Service Executive, Department of Health and Children and National Council on Ageing and Older people, and published in June 2008. This gave the estimates of the incidence of osteoporosis and stated that one in three women and one in five men over the age of 50 years may have osteoporosis in Ireland, although they may be unaware of this until their first fracture occurs.
Consequently, the study concluded that based on extrapolations from World Health Organisation data the number of people in Ireland over 65 with osteoporosis was around 120,000
The Strategy noted that while national statistics on osteoporosis were incomplete, in 2004 there were 6,113 hospital episodes where a diagnosis of osteoporosis was recorded and the Strategy suggests that this was the “tip of the iceberg”.
From an economic perspective the Strategy estimated that the total cost of falls to the health service is €402 million p.a., and osteoporosis is a significant contributing factor to this cost. It should also be noted that €24.8m was directly attributed to the cost of medications for the treatment of osteoporosis.
The Strategy goes on to make a number of recommendations in relation to osteoporosis risks and best practice in relation to prevention, management and treatment. This includes the recommendation that prevention, treatment and management require a long term approach beginning in childhood; that prevention should be life long and focus on improving awareness of bone health in particular Calcium and Vitamin D intake; the benefits of physical activity and the risks of smoking for bone health.
Therefore, I believe to remove cheese as part of a sensible and healthy diet consumed by children would run contrary to the Department of Health policy on osteoporosis.
The message must go out to parents that cheese should be consumed as part of a balanced and healthy diet and that exercise for children is equally as important as their diet.
As a result I would request that an exemption be included in the children’s commercial communications code to exclude cheese from any proposed advertising restrictions by recognising cheese as a valuable source of calcium.
I hope that you can look favourably upon this request,
Denis Naughten TD
1. Hayes E et al. Proc Nutr Soc. 2008; 67 (OCE7): E275.
2. Hannon EM et al. Ann Nutr Metab. 2005; 49: 256..